ScramCard recognises the importance of safeguarding the personal information of its customers.

The following Privacy Policy sets out the basis on which any of your personal information will be collected, stored and used by us and reflects ScramCard’s commitment to maintain the confidentiality of personal information and to provide its customers with the best possible service.

Please read this Privacy Policy carefully.

This website is provided by ScramCard Global (Hong Kong) Limited and describes our use of your personal information when you use this website.

We do share your personal information with the Tuxedo Group (which includes Tuxedo Money Solutions Ltd, Tuxedo Money Card Ltd and Tuxedo Money Plus Ltd) who deliver ScramCard Services to you. Tuxedo Group will have their own Privacy Policy with which you should familiarise yourself.

Information we collect

We collect and process personal information in the following ways:

Information you give us

Personal Information. When you use the ScramCard Services, we may ask for information about you. This may include your name, date of birth, home address, billing address, office address, e-mail address, mobile telephone number, credit or debit card information, as required by us in order to complete your transaction and provide you with access to the ScramCard Services. If you do not provide the information we require, we may not be able to provide you with access to the ScramCard Services.

Information we collect from your use of our services

We may collect information about you, the ScramCard Services and how you use them. This could include:

Transactional information about our Services and how you use them

Information you share with us when you contact us for any reason either in writing, by phone or by any other means

Registration details when you activate an account within our range of ScramCard Services

Content you post on our websites, including personal descriptions, photographs and videos

Information when you take part in promotions, competitions or surveys

Details of your visits to the Online Services. This includes page interaction and Online Services site activity, including which website you came from and pages your viewed during your visit

Data collected by cookies and corresponding technologies, together with the personal information we have collected

Location information, for example your IP address

Information we receive from third parties

We may also receive information from third parties. This may include:

Non-personal information used to supplement existing information, such as demographics and affluence metrics (e.g. social-demographic groupings through matching postcode information)

Information about you from other sources with whom we work closely to provide the ScramCard Services to you.

How we use the information we collect

We may use your information for the following purposes:

Using our partners to fulfill your order for a ScramCard Service, collect payment, and otherwise provide you with the information, products and services you may request from us

Complying with our and our partner’s legal and regulatory obligations (including fraud prevention, anti-money laundering and sanction screening). This may include checking the information you provide to us against information from other sources

Enforcing any contract entered into between you and us for the ScramCard Services

Contacting you (including by email or SMS) with marketing messages according to your preferences

Providing you with any alerts, in App messages or other messages you have registered to receive

Providing you with service messages, notifying you about changes to our Services or changes to our terms, conditions and policies.

Improving customer experience and our quality of service

Data analysis to allow us to derive insight and to help us improve the ScramCard

Services

Information we share

We do not share personal information with companies, organisations or individuals outside of ScramCard for marketing purposes or otherwise, nor do we sell your personal information.

The only time your personal information may be used in such a manner that it can be shared with a third party is if:

We are purchased by a third party, in which case personal information that is available to us through out partners, including you as our customer will be transferred. We will notify you of this through the most appropriate means

We have aggregated, non-personally identifiable information, which is to be used for segmentation, statistical modeling, general research or trend analysis

We need to comply with the obligations we have to our third party product issuers or third parties providing products or services on our behalf, so that they may process your order or otherwise provide the information, products or services you have requested (please note that these third party product issuers have their own privacy policies and accordingly we cannot accept any responsibility or liability for the handling of personal information by such third parties in accordance with such policies)

We are under a duty to disclose or share your personal information that’s available to us through our partners in order to comply with our legal obligations or in order to enforce our conditions of sale and other agreements; or to protect the rights, property, or safety of ScramCard, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

Retention of Personal Information

ScramCard only retains your information for as long as is necessary for us to use your information as described above or to comply with our legal obligations. However, please be advised that we may retain some of your information after you cease to use Scramcard services, for instance if this is necessary to meet our legal obligations, such as retaining the information for tax and accounting purposes.

Maintenance of Accurate Information

We strive to ensure that the information we pass to our partners to maintain about our customers is accurate, current and complete. We respond to requests from customers to correct inaccurate information in a timely manner so please tell us if you think our partners hold incorrect information about you on our behalf by emailing us at [email protected]

Security

Our partners have security measures in place to protect your personal information and you should review their privacy policy before submitting personal data to them through the ScramCard Services. However, when transmitting personal information over the internet, please bear in mind that no transmission over the internet can ever be guaranteed secure. Therefore, please note that we cannot guarantee the security of any personal information that you transfer over the internet to us.

Cookies

Cookies are common and do not harm your system. Cookies are small text files placed on your computer, tablet or phone by a web browser or by an app, which have been sent to you by a web server or when you install an app; they simply store or gather site information such as iOS, language etc. It is essentially an identification card relating to you. Cookies help you do things online and in-app, like remembering your login details so you don’t have to re-enter them when revisiting a site.

We use cookies to:

Gather customer journey information across our sites and within apps;

Ensure your privacy in our secure sites and apps;

Store log-in details for our secure sites and apps.

We don’t use cookies to track people’s internet usage after leaving our sites and we don’t use them to store personal information that others could read and understand. We will not sell or distribute cookie information without your prior consent.

You can disable cookies from your computer, tablet or phone by following the instructions at www.allaboutcookies.org. However, if you do not accept incoming cookies then the performance of our websites or apps may degrade, and in some cases you may not be able to use them at all.

Links to Third Party websites

Our Website may, from time to time, contain links to and from the websites of our selected partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and accordingly we cannot accept any responsibility or liability for such policies. It is therefore advisable to check these policies before you submit any personal information to these websites.

Access to Information

If you require access to the information we hold about you, as detailed above, please email us at [email protected]. Any request may be subject to a small fee, where we are legally permitted to charge in order to meet our costs in providing you with details of the information we hold about you.

We strive to ensure that the information we maintain about you is accurate, current and complete. We respond to your requests to correct inaccurate information in a timely manner so please tell us if you think we hold incorrect information about you via email at [email protected].

Children’s Privacy

ScramCard does not knowingly collect or solicit personal information from individuals under 13 years of age. If you are under 13 years of age, you should not register or provide personal information to ScramCard. If we later obtain actual knowledge that a user is under 13 years of age, we will take steps to remove that a user’s personal information from our systems. If you believe that we might have any information from or about a child under 13, please contact us at [email protected].

Providing personal information about other people

You can provide us with another person’s personal information to enable us to ship gift cards to them to allow applications to be made for access to ScramCard Services.

This information will not be retained by ScramCard once the gift card has been dispatched to the person whose information you have provided us with.

You may want to discontinue receiving information from us. While this may mean that you will not receive product, service or promotional information of interest to you, we respect anyone’s wishes not to be informed directly.

If you no longer wish to receive notifications and communications please e-mail [email protected]

You will also be provided with an unsubscribe link in any email or SMS marketing message we send you.

Changes to Our Privacy Policy

Any changes we make to our Privacy Policy in the future will be posted on our website. Please do check our Privacy Policy from time to time to take notice of any changes made. By providing us with your personal information, using the Online Services and/or any service or product offered via the Online Services or via our partners’ services, after we have changed the terms of our Privacy Policy, you will be deemed to have accepted these changes. We will advise you of significant changes to this Privacy Policy where we have access to your contact details.

This Privacy Policy was last updated on 16th May 2017.

Contact

Questions, comments and requests regarding this Privacy Policy are welcomed and should be emailed to [email protected]